86 CULTURAL RIGHTS particularly with regard to indigenous peoples. The United Nations Development Programme (UNDP) has the most detailed and rights-based policy statement.22 The policies of the World Bank23 and Asian Development Bank 24 also contain some degree of protection. The Inter-American Development Bank is presently drafting a policy on indigenous peoples that recognizes a range of cultural rights.25 These organizations have not adopted specific policies applying to minorities, although both the World Bank and Inter-American Development Bank have applied policy guarantees related to indigenous peoples, to Afro-American communities in Latin America and the Caribbean. The UNDP is presently drafting a policy on minorities that will apply to its projects. As a general principle, the right to culture entails both negative and positive obligations. Negative in the sense of the obligation to respect cultural rights they shall not be denied; and positive insofar as states are required to provide resources and take other measures to guarantee and protect the exercise of cultural rights.26 There are also limits imposed on cultural rights by other human rights. The HRC has stated that ‘none of the rights protected under Art. 27 of the Covenant may be legitimately exercised in a manner or to an extent inconsistent with the other provisions of the Covenant’.27 Under ICEDAW (Art. 5), as well as other conventions, states are obligated to modify or prohibit traditional or cultural practices harmful to women.28 Much of the international jurisprudence on cultural rights counts the extent to which indigenous peoples and minorities were consulted and participated in decision-making as an important criterion in assessing the existence and extent of violations.29 In the case of indigenous peoples, the requirement of free, prior and informed consent is increasingly employed as the appropriate standard of participation.30 Enforcement mechanisms The UN is presently discussing an optional protocol to the ICESCR that, in its present form, will permit individuals and groups to file complaints concerning perceived violations of the rights guaranteed therein, potentially including violations of the right to self-determination.31 Discussions and negotiations are ongoing and it is likely be several years before this mechanism is adopted and opened for states to the Covenant to ratify. The World Bank established an enforcement mechanism known as the Inspection Panel in 1993 to receive complaints concerning compliance with its policies.32 Similar mechanisms have also been established by the Inter-American and Asian Development Banks.33 The Inspection Panel’s Operating Procedures permit two or more individuals who allege harm caused by violations of Bank policies to submit claims if they have been unable to resolve the matter with Bank